Memorandum Findings of Fact and Opinion
WITHEY, Judge:
A deficiency has been determined by respondent in the income tax of petitioner for the taxable year February 1, 1957 to January 31, 1950, in the amount of $41,585.39. The sole issue is whether in a sale of certain real property petitioner realized capital gains or ordinary income.
Findings of Fact
The facts which have been agreed upon are found as stipulated.
Petitioner was...
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